Senators Chris Dodd (D-CT) and Joe Lieberman (ID-CT), along with Representatives Christopher Shays (R-CT-4) and Chris Murphy (D-CT-5), today sent a letter to Federal Aviation Administration Acting Administrator Robert Sturgell requesting that the FAA carry out the analyses recommended by the Government Accountability Office (GAO) in its report on the FAA’s proposed airspace redesign.  The Connecticut elected officials also requested that the FAA respond to several shortcomings highlighted in the GAO report and present a detailed airspace redesign implementation plan to Congress that includes a time and cost schedule, risk mitigation plan, transition planning, and monitoring and evaluation plan.

“The FAA has a responsibility to limit the affect of this project on the millions of Americans living in the redesign area.” said Dodd.  “The GAO report issued last month raised numerous questions about the evaluation of the redesign alternatives and the future of this project.  The families of Connecticut should not have to have their quality of life adversely affected due to a redesign project that has not been adequately scrutinized by the FAA.”

“I urge the FAA to consider seriously our request for both additional analysis of the proposed airspace redesign and a detailed redesign implementation plan,” said Lieberman.  “The FAA has an obligation to address the legitimate concerns of the people of Connecticut, New York, New Jersey and Pennsylvania.” 

“As the original GAO study points out, there are methodological limitations of the FAA’s preferred alternative for redesign that warrant further inquiry,” said Shays.  “Given the impact the redesign will have on the standard of living in Connecticut, it is absolutely imperative to have a comprehensive review of this redesign before we can even begin to assess its effects on our communities.” 

“Connecticut residents are being asked to live with an airspace redesign plan that they know very little about,” said Murphy.  “It’s time FAA leveled with residents and made it clear what the redesign plan really means for Connecticut, and answer all of our unanswered questions before they rush forward with this proposal.”

The full text of the letter is below:

Dear Acting Administrator Sturgell,

We are writing in response to the Government Accountability Office (GAO) report released in August that outlined shortcomings in the Federal Aviation Administration’s New York/New Jersey/Philadelphia airspace redesign plan.  In light of GAO finding that further measures would benefit decision makers and the public, we request the Federal Aviation Administration (FAA) to perform additional analyses for the redesign alternatives and submit a detailed implementation plan with a schedule. 

According to the FAA, the stated purpose of the airspace redesign project is to increase safety and efficiency.  We are concerned, however, that the FAA’s stated purpose and underlying rationale that flight operations would not result in increased traffic because the system’s overall capacity is not increased, may prove unrealistic.  The GAO cited conflicting information in the “FAA’s National Airspace Capital Investment Plan FY2008-2012,” which lists as an objective of the airspace redesign increasing capacity to meet projected demand and reduce congestion.  Furthermore, the GAO found the FAA’s assumption that travel demand will not increase to be contrary to economic theory and internal FAA guidance.  Since the FAA failed to provide economic evidence to support its underlying rationale that traffic demand and flight operations will not change as a result of system improvements, we remain concerned over how the FAA came to several of its conclusions for selecting the redesign project.

Accordingly, we request a thorough review of surrounding issues raised by the GAO before the FAA proceeds with the redesign. 

• Uncertainty Analysis.  According to the GAO, the FAA should have assessed uncertainty by evaluating how changes in key assumptions in the demand forecast would affect the estimated impacts of the alternatives.  The FAA did not consider how jet fuel costs would impact ticket prices and airline operations.  The oversight of this key factor is significant, considering airlines reduced flight services as a result of record high prices this summer.  We request that the FAA conduct a full sensitivity analysis on the demand forecast’s key assumptions and the relative impact of the competing alternatives.

• Effects of System Improvements.  The FAA did not account for the potential affect of system improvements on current airspace capacity.  The GAO indicated that the FAA’s assumption in the noise analysis did not fully account for the future use of Area Navigation (RNAV) technology.  Under this assumption, the FAA did not model RNAV in the noise analysis used to compare the alternatives.  Advanced technology such as RNAV or NextGen increase efficiency by reducing fuel burn and flight time and provide more accurate information on noise impacts.  Since the FAA’s own estimates indicate that 80 percent of operations at the top 35 busiest airports in the National Airspace System are RNAV capable, we request that the FAA examine RNAV procedures and NextGen applications in the noise analyses for the alternatives.

• Benefit-Cost Analysis.  According to the GAO, the FAA did not fully evaluate the economic impacts, such as implementation costs, in the current redesign process.  Nor did they evaluate the effect of the alternatives on the airlines and passengers, or estimate the affect of noise on the quality of life of residents living near the airports.  The FAA asserts that the redesign will reduce the annual operating costs of airlines by an estimated $285 million.  In our view, the FAA’s claim that the Integrated Airspace of the ICC is the only alternative “worth the effort and expense of implementing an airspace redesign of this magnitude” is not supported with evidence.  In fact, the GAO determined that since the FAA did not estimate costs, the information on benefits cannot be used to assess whether the selected project is economically justified.  Since the GAO believes that a benefit-cost analysis can provide valuable information for decision makers and should be considered in analyzing transportation investments, we request that the FAA provide a full benefit-cost analysis, clearly comparing the impact of the alternatives to the airline industry, residents within the redesign area, and the Federal Aviation Administration.

• Implementation Plan.  The FAA has not yet developed a detailed implementation plan that includes a schedule of when the new redesigned airspace will be in place.  Additionally, the FAA has not yet determined the type or amount of equipment or software that will be needed to implement the project.  We request that the FAA provide a detailed implementation plan that includes a time and cost schedule, risk mitigation plan, transition planning, and monitoring and evaluation plan to Congress before moving forward with the redesign. 

Thank you in advance for addressing these specific concerns.  We appreciate your willingness to provide comprehensive information on the redesign evaluation for the public and Congress.

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